If approved, the fund would invest in a portfolio which includes “high-quality, short-term sovereign debt instruments listed for trading on U.S. exchanges and denominated in U.S. dollar, euro, British pounds sterling, Japanese yen and Swiss francs,” as well as bitcoin futures, money market mutual funds and/or other cash equivalents, according to the form.

The fund would invest in cash-settled bitcoin futures contracts, rather than physically settled. In other words, when the contract expires, the investor would receive the cash equivalent of its value, rather than bitcoins. According to the form, “the fund will not invest directly in bitcoin.”

The form explains:

“The Adviser initially constructs the Fund’s portfolio by investing approximately (i) an equal-weight of 15 [percent] of the Fund’s net assets in Fixed Income Securities denominated in each Fiat Significant Global Currency; (ii) 15 [percent] of the Fund’s net assets representing notional exposure in Bitcoin Futures and (iii) 10 [percent] of the Fund’s net assets in Money Market Instruments for margin and/or cash management purposes, each as measured at the time of purchase (the ‘Target Portfolio’).”

Reality Shares’ filing goes on to add that “the Adviser seeks to reallocate the Fund’s assets approximately to the Target Portfolio on the business day following the date that one or more of the Significant Global Currencies moves by more than 20 [percent] up or down from its original 15 [percent] portfolio equal-weight, calculated as a percentage of the Fund’s net assets.”

Initially, Reality Shares plans to invest in the bitcoin futures offered by Cboe and CME, though it might look for other bitcoin futures products in the future.

Bitcoin ETFs

Reality Shares’ proposal comes on the heels of two bitcoin-specific ETF filing made by Bitwise Asset Management and VanEck/SolidX last month. While Bitwise’s proposal has also been filed by NYSE Arca, VanEck and SolidX are working with Cboe BZX Exchange.

Both of these bitcoin ETFs differ from Monday’s filing in that they do not include sovereign debt instruments.

The SEC has not yet published the rule change proposal on its website, indicating that it has not yet begun examining the product. Once the proposal is published in the Federal Register, the SEC will have at most 240 days to determine whether to approve or reject the rule change proposal.